ecp #2.4 export license procedures for tangible …...apr 04, 2014 · ecp #2.4 export license...

ECP #2.4 EXPORT LICENSE PROCEDURES FOR TANGIBLE

EXPORTS AND COLLABORATING WITH NON-U.S. PERSONS

Released 4-4-2014

ECO- 2.4 4/4/2014 page 1 rev A

I. Purpose

To ensure that all exports are analyzed for license requirements, and if required, export licenses

are obtained from the appropriate government agencies. The purpose of this procedure is to

standardize and facilitate the prior review and approval of SI’s exports that may be subject to

the International Traffic in Arms (ITAR) - or Export Administration Regulations- (EAR) -

restricted goods and technology.

If items or data are hand carried or checked onboard an aircraft, please also review Policy and

Procedure for Traveling with Equipment and Research-related Materials.

II. Procedure

1. The ECO informs PIs and PMs about the need to obtain an export license through on-going export

compliance review of grants and contracts and advisories sent to advisors semi-annually. (See

Attachment 1). The ECO works with PIs and their PM to complete the ITAR/Export Determination

Checklist (Attachment 2) with the facts of the transaction or collaboration with a foreign person.

(Foreign National Export license form Attachment 3 form ECP 5).

2. Through communication with the PI and PM, the ECO or ECO-backup determines the

program and purpose of the export

items or technical data to be exported

parties and countries involved

value and origin of the equipment, if applicable

length of time the equipment is staying and if it is coming back, if applicable.

For deemed exports (providing export controlled data to a non-U.S. person in U.S.) obtain

information about the length of time the foreign person will be working on the program. The

validity of a license will correspond to the expiration of their visa.

3. The ECO works with the PI/PM to determine the export classification. The PI consults with the

sponsor to inquire if the program is ITAR or EAR controlled.

4. For an equipment export, the PI or requestor provides the details of the transaction on the Export

Checklist. Details may be added over time, not all the information is necessarily available at the

start of the process. See forms XXX ITAR/Export Determination ECO-1 and Export Checklist. ECO-2.

5. If there is no determination from the sponsor, the PI and ECO review the Statement of Work,

equipment, location, etc. and ITAR US Munitions List and EAR Commerce Control List to determine

the type of export and the category and/or Export Control Classification Number. The ECO

communicates with the PI or PM to identify if the item to be exported meets the parameters of



Released 4-4-2014

ECO- 2.4 4/4/2014 page 2 rev A

listed items and if a license is required. The ECO then reviews any license exceptions or exemptions

that might apply. The ECO completes the ITAR/EAR license determination. (If the contemplated

export is a deemed export, there is an exemption 125.4 b. 11 we can take advantage of is the on

U.S. person is a full time employee.)

6. If no exception/exemption applies, the ECO completes the appropriate export license application

form, (ITAR DSP-5 of Technical Assistance Agreement or EAR BIS form 748P, or OFAC form ), for

temporary or permanent export. For this, the ECO requires the PI to provide the quantity,

description, brochure or technical specifications and value of the shipment.

7. The ECO determines what supporting documents need to be attached to the license application to

comply with the government’s review of the transaction, such as

end-user statement

for foreign national license: visa, passport, resume, cover letter describing job description,

technical data to be provided, the output of their work, statement of work. A foreign national

license form ECP-5 captures the information – see sample

import certificate for EAR licenses valued at over $50,000 to countries listed in 748.9

statement of work

contract or purchase order

sample technical data or drawings.

8. Prior to submission, the draft of the license is sent to the PI and PM for review, comments and their

approval. Once approved, the license forms, pdf versions and unsigned forms are placed in the

shared drive V:7 Export Controlled Awards.

9. If the license is a Technical Assistance Agreement (TAA) with hardware associated with it, the PI or

PM must provide a description and dollar value of the exported hardware, whether it is permanent

or temporary (coming back). The ECO provides the prepared license or TAA draft and transmittal

letter to all proposed signatories prior to submission to DDTC for their consent or proposed

revisions.

10. For ITAR licenses, the ECO “validates” the license form, and then signs the license digitally before

uploading. For EAR licenses, the ECO checks for errors and submits.

11. If the license has provisos from the Dept. of Defense, the ECO reviews the provisos and

communicates them to the PI and PM prior to acceptance and license issuance. If a foreign national

license for a SI/SAO-affiliated person, the ECO provides the non U.S. person a Non-Disclosure

agreement to sign. – see Attachment



Released 4-4-2014

ECO- 2.4 4/4/2014 page 3 rev A

12. If the technical data is EAR controlled and qualifies for a Technology and Software Under Restriction

license, the ECO has the Non-U.S. persons sign the TSR Letter. See Attachment -

13. The ECO ensures that the PM and PI receive a written copy of provisos and are informed how to

show evidence of complying with them.

14. The ECO works with the PI/PM to determine the export classification. The PI consults with the

sponsor to inquire if the program is ITAR or EAR controlled.

15. For an equipment export, the PI or requestor provides the details of the transaction on the Export

Checklist. Details may be added over time, not all the information is necessarily available at the

start of the process. See forms XXX ITAR/Export Determination ECO-1 and Export Checklist. ECO-2.

16. If there is no determination from the sponsor, the PI and ECO review the Statement of Work,

equipment, location, etc. and ITAR US Munitions List and EAR Commerce Control List to determine

the type of export and the category and/or Export Control Classification Number. The ECO

communicates with the PI or PM to identify if the item to be exported meets the parameters of

listed items and if a license is required. The ECO then reviews any license exceptions or exemptions

that might apply. The ECO completes the ITAR/EAR license determination. (If the contemplated

export is a deemed export, there is an exemption 125.4 b. 11 we can take advantage of is the on

U.S. person is a full time employee.)

17. If no exception/exemption applies, the ECO completes the appropriate export license application

form, (ITAR DSP-5 of Technical Assistance Agreement or EAR BIS form 748P, or OFAC form ), for

temporary or permanent export. For this, the ECO requires the PI to provide the quantity,

description, brochure or technical specifications and value of the shipment.

18. The ECO determines what supporting documents need to be attached to the license application to

comply with the government’s review of the transaction, such as

end-user statement

for foreign national license: visa, passport, resume, cover letter describing job description,

technical data to be provided, the output of their work, statement of work. A foreign

national license form ECP-5 captures the information – see sample

import certificate for EAR licenses valued at over $50,000 to countries listed in 748.9

statement of work

contract or purchase order

sample technical data or drawings.

19. Prior to submission, the draft of the license is sent to the PI and PM for review, comments and their

approval. Once approved, the license forms, pdf versions and unsigned forms are placed in the

shared drive V:7 Export Controlled Awards.



Released 4-4-2014

ECO- 2.4 4/4/2014 page 4 rev A

20. If the license is a Technical Assistance Agreement (TAA) with hardware associated with it, the PI or

PM must provide a description and dollar value of the exported hardware, whether it is permanent

or temporary (coming back). The ECO provides the prepared license or TAA draft and transmittal

letter to all proposed signatories prior to submission to DDTC for their consent or proposed

revisions.

21. For ITAR licenses, the ECO “validates” the license form, and then signs the license digitally before

uploading. For EAR licenses, the ECO checks for errors and submits.

22. If the license has provisos from the Dept. of Defense, the ECO reviews the provisos and

communicates them to the PI and PM prior to acceptance and license issuance. If a foreign national

license for a SI/SAO-affiliated person, the ECO provides the non U.S. person a Non-Disclosure

agreement to sign. – see Attachment

23. If the technical data is EAR controlled and qualifies for a Technology and Software Under Restriction

license, the ECO has the Non-U.S. persons sign the TSR Letter. See Attachment -

24. The ECO ensures that the PM and PI receive a written copy of provisos and are informed how to

show evidence of complying with them.

III. References

SD 611 Export Compliance and Trade Sanctions Related to Research, Export and Museum Activities

Contact: Natascha Finnerty, Export Compliance Officer about questions related to this procedure at

[email protected] and telephone is (617) 496-7557.

Definitions

Applicant – company or organization that is registered with the Directorate of Defense Trade Controls

(DDTC) or Bureau of Industry and Security (BIS) to file license applications through the internet using

their secure license portals.

Bureau of Industry and Security (BIS) – Agency in the Department of Commerce that processes dual use

and commercial license applications for export.



Released 4-4-2014

ECO- 2.4 4/4/2014 page 5 rev A

Category – the section of the US Munitions List where the item to be exported is classified. Category XV is Space-related items, Category XII is infrared and optics. The Commerce Control List has Categories 0 – 9. Commerce Control List (CCL) – A list of items under the export control jurisdiction of the Bureau of Industry and Security, U.S. Department of Commerce. Note that certain additional items described in part 732 of the EAR are also subject to the EAR. The CCL is found in Supplement No. 1 to part 774 of the EAR. http://www.bis.doc.gov/policiesandregulations/ear/index.htm D-Trade 2 – portal used by the DDTC to file export license applications. End-user information – both DDTC and BIS require detailed end-user information about where the item or technology will be used and by whom and for what purpose. Export Administration Regulations (EAR) – regulations set forth in 15 CFR Parts 730 – 774 over the export of commercial, dual-use, strategic and other items subject to foreign policy controls. Export Control Classification Number (ECCN) – 5-digit alphanumeric number assigned to dual-use or commercial items, production and test equipment, materials, software and technology that are controlled for export by an export regime or US government. Electronic Export Information – filing made electronically to the Bureau of Census through their Automated Export System to report exports under an export license or license exception/exemption or valued over $2500. Foreign Consignee – non U.S. party with whom SAO has direct relationship and/or contractual agreement. International Traffic in Arms Regulations (ITAR) – 22 CFR Parts 120 – 130, regulations issued by the Political and Military Affairs office of the US Department of State governing the registration, authorization of transfer and enforcement of these regulations related to items, services and technical data designated as defense articles. Registration Number – the number assigned to SI in their registration letter from the Directorate of Defense Trade Controls (DDTC), US Department of State. It is a government agency so it starts with a G and needs to be listed on the license. Schedule B Number – US-only number (10 digits XXXX.XX.XXXX format) that identifies the item for the purposes of calculating our balance of trade. Only used for exports. Significant Military Equipment (SME) – certain defense articles preceded by an asterisk in the US Munitions List. Technical data directly related to the manufacture or production of any defense articles enumerated in any category that are designated as SME shall itself be designated SME. SNAP-R – portal used by the BIS to file export license applications. Technical Assistance Agreement (TAA) – export license issued by the US State Department to authorize discussions and technology transfers of item on the US Munitions List that are on-going to approved partners.

http://www.bis.doc.gov/policiesandregulations/ear/index.htm



Released 4-4-2014

ECO- 2.4 4/4/2014 page 6 rev A

US Munitions List (US ML) – Part 121 of the ITAR that consist of items, services and related technical data that are designated defense articles and defense services pursuant to 38 and 47(7) of the Arms Export Control Act (22 U.S.C 2778 and 2794(7)). SAO’s Company ID number with the Dept. of Commerce is S384411. The registration number with DDTC is G-7000. NOTE 1: Guidelines for applying for licenses are on DDTC website and are detailed in Part 123 and 124 of the ITAR: http://www.pmddtc.state.gov/licensing/index.html. DDTC licenses must be signed by an empowered official with a digital certificate and submitted by an approved submitter on the D-Trade license portal. http://www.pmddtc.state.gov/regulations_laws/itar_official.html NOTE 2: EAR license preparation procedures are described in Part 748 of the EAR and the license is submitted through the Bureau of Industry and Security license portal called SNAP-R. http://www.bis.doc.gov/snap/index.htm A user manual for SNAPR is posted on the SNAPR site. Submitters must have an approved SNAPR-R ID but no digital signature is required

Responsibilities Export Compliance Officer (ECO) makes a license determination, interviews the PI, applies for the license and manages the release/export of data or items. Principal Investigators (PI) provide the Statement of Work, assistance the classification of the program, and the details of the data/items that non US persons will receive and what they will be using it for Program Managers (PM) facilitate the process where necessary

Records The following are considered export compliance records to maintain for five years: Emails or other communications about the proposed export

License applications sent to the appropriate government agencies with supporting

documents

Approved licenses with provisos

http://www.pmddtc.state.gov/regulations_laws/itar_official.html

http://www.bis.doc.gov/snap/index.htm



Released 4-4-2014

ECO- 2.4 4/4/2014 page 7 rev A

ATTACHMENT 1: LETTER TO ADVISORS

[Date]

LETTER TO ADVISORS AND POTENTIAL ADVISORS

TO PRE DOCS AND POST DOCS

As a research organization, Smithsonian Astrophysical Observatory (SAO) is required by

federal law to safeguard and/or obtain approval for the transfer of hardware, software and

technical data to non-US persons for research projects that are outside of the “fundamental

research” or “public domain” parameters. I am the Export Compliance Officer, and I am working

with a team to identify projects that subject SAO to export controls per the regulations below.

Once identified as export controlled, we need to know if the project has foreign-national or

export restrictions.

As you are an advisor of a non-US person who is not a full-time employee, we need you to

ensure that he/she is not working on any program that is export controlled without prior

authorization via an export license. Students, fellows and interns who only work with

observation data are exempt from export controls as their work is “fundamental research.”

The types of programs that are controlled at SAO are those dealing with technical data and

hardware related to certain space or ground-based instrumentation mounted on or used

in spacecraft, satellites, and data or software related to their propulsion and control

systems. Additionally, research related to focal plane arrays, infrared detectors,

deformable mirrors, space-qualified adaptive optics, radiation hardened electronics,

digital signal processors, and atomic clocks, etc. is controlled.

If you believe your student/fellow/intern has access to or will need access to the above

instruments or technology in the future, please contact me as soon as possible. Persons from

certain countries are not eligible to have access to certain technology, and SAO would be held

liable for a violation.

Technology-based export controls start with a determination of whether the item or technology

is listed on one of the two export control lists. The two lists are part of the export regulations

listed below:

International Traffic In Arms Regulations (ITAR) (22 CFR Parts 120 – 130) (link to

BITAR) are administered by the US Dept. of State, Directorate of Defense Trade

Controls (DDTC). These regulations control items and related data deemed to provide a

military advantage. They are enumerated on the US Munitions List, which includes

spacecraft and infrared technologies; research satellites, space vehicles, space qualified

optics, thruster technology, ground stations, encryption for military use and guidance

systems, among other specially designated defense items. We must interface with

DDTC when obtaining approval for technology transfers to non-US persons.



Released 4-4-2014

ECO- 2.4 4/4/2014 page 8 rev A

Export Administration Regulations (EAR) (15 CFR Parts 730 – 774) regulate all other

commercial items that are exported, including some items that may require a license

from the US Department of Commerce, Bureau of Industry and Security (BIS). Items

that may need a license are listed on the Commerce Control List (Part 774 of the EAR)

and include such items as lower-level IR cameras, X-ray optics, radiation-hardened

electronic components, some cryro-cooled optics and lasers, super computers, coatings,

propulsion, encryption and all technology related to these items. These items are subject

to safeguard requirements, such as restricted access to files and information by non-US

persons (those who are here on a student or work visa), when they are in our

possession, in either hard copy or electronic form, and restrictions from lab areas where

research is being performed.

We would like to arrange a meeting to further explain the export regulations process and

discuss your project. During the meeting or at a follow-up meeting, we can evaluate your

research and lab equipment against the US Munitions List and the Commerce Control List. If

your research has any of these technologies, then we will need to inquire about how you

safeguard the items, instrumentation, and files and identify the persons working with you. We

also need to determine if there are any limitations to the detail of what can be broadly discussed

and published.

To prepare for this meeting, we are attaching a compilation of entries on the Commerce Control

List and US Munitions List for you to review in advance that may pertain to your research. After

the meeting, we may determine other areas of the lists that need to be researched.

If you have any questions, contact our Export Compliance Officer, Natascha Finnerty at

[email protected] or her phone at 617-496-7557.

http://www.bis.doc.gov/index.php/regulations/export-administration-regulations-ear

mailto:[email protected]



Released 4-4-2014

ECO- 2.4 4/4/2014 page 9 rev A

ATTACHMENT 2

DETERMINATION OF EXPORT CONTROL APPLICABILITY

DATE: ___________________

Completed by: ______________

NAME OF CONTRACT/PROPOSAL

DESCRIPTION CONTRACT NUMBER DESIGNATED CODE

PROJECT MANAGER/PRINCIPAL INVESTIGATOR WITH EMAIL AND PHONE

PI PM

Technical Data (TD) Assessment RESPOND TO QUESTIONS BELOW

Y OR N

1 Does the contract restrict publication or presentation of results?

2 Will information disclosure require NDA?

3 Is there controlled encryption software and hardware bundled with encryption? (over 64 bits not for password protection or

authentication)

4 Are there export license clauses or information security provisions?

5 Are foreign sponsors/collaborators involved?

6 Is it for NASA and they have foreign national restrictions?

7 Does the project include controlled equipment under the ITAR or EAR, like IR cameras, telemetry technology, rad hardened components, IR detectors, rockets, vacuum chambers, optical bench, lasers, solar cells, UAVs or missile technology?

8 Does research involve foreign travel? (Ensure it is not to an embargoed country? China, Cuba, Iran, North Korea, Sudan, Syria?)

ECO If ITAR, and a deemed export, does higher learning exemption apply to the partner with the foreign national?

ECO Does multi country ITAR NASA exemption apply?

Assessment of Fundamental Research Signature

YES, Qualifies as Fundamental Research

NO, It does not qualify – ITAR or EAR (circle)

If controlled, provide the following:

SAO personnel who will have access to export controlled information

DATE OF TRAINING

Name 1.



Released 4-4-2014

ECO- 2.4 4/4/2014 page 10 rev A

2.

3.

4.

Other US persons who will have access – name, title, institute

1.

2.

3.

4.

Foreign parties with approved access

SIGNED NDA’S AND TRAINING

Name (in US) or organization (not in US)

1.

2.

3.

4.

Sub licensees organization (not in US)

1.

2.

3.

4.

5

SCREENING OF ALL PARTIES AGAINST DPL AND SDN

DPL report on file?

HARDWARE EXPORTS AND DESCRIPTION (Temporary or permanent, controlled under ITAR or EAR.) If yes, complete hardware questionnaire Proposed date

TECHNOLOGY AND HW RELEASE ROAD MAP

MARKING OF DOCUMENTS AND RECORDS OF MEETINGS AND TELECONS

IT security plan

Marking convention

Responsible for records of meetings and telecons (participants)

Sign off: ECO



Released 4-4-2014

ECO- 2.4 4/4/2014 page 11 rev A



Released 4-4-2014

ECO- 2.4 4/4/2014 page 12 rev A

ATTACHMENT 3

SAO FOREIGN NATIONAL INFORMATION FORM FOR EXPORT LICENSE

If your research is export controlled and you wish to work with a non-U.S. Person who is not a full time

employee, then this is a “deemed export.” If your program is export-controlled or if your equipment that

they will be using is export controlled, then we will need to obtain an export license. Please assist by

providing the information below.

SUBMITTED BY:

PROGRAM:

CONTRACT NO/DESIGNATED CODE

SPONSOR AND PRIME:

TECHNICAL CONTACT NAME:

CONTACT INFO:

Information needed for

license

Name Gonzalo xxx

Address in US 14 Main Street,

Somerville, MA 02143

Address in home country Calle Quixote 4-24

46014 Madrid

Spain

Nationality Spaniard

Passport – Date Checked that

it is valid

9-11-2020

VISA – Date Checked that it

is valid

10-31-2014

Resume – Attached

Cover Letter PI name

Explain your program, what the person will be working on, what

technology they need to have access to in order to perform their job, in

what form the technology will be – attach



Released 4-4-2014

ECO- 2.4 4/4/2014 page 13 rev A

Sample Data Input Scientific paper about a different satellite

Ozone monitoring instrument

Sample Data Output

Job Description To be provided by PI

Org Chart where FN is

located in Unit

Optical and Infrared Astronomy (OIR)

Technology Control Plan ECO

Completed, reviewed DSP5

or form BIS 748P

ECO

Proper Statement in item 20 –

of DSP-5 “For Employment in

the United States of a foreign

national who will …”

ECO

Information about ties to US –

relatives, any real estate

owned

No family in US

ECP-5



Released 4-4-2014

ECO- 2.4 4/4/2014 page 14 rev A

ATTACHMENT 4 DSP-5- SAMPLE STATE DEPT LICENSE FOR HARDWARE



Released 4-4-2014

ECO- 2.4 4/4/2014 page 15 rev A



Released 4-4-2014

ECO- 2.4 4/4/2014 page 16 rev A



Released 4-4-2014

ECO- 2.4 4/4/2014 page 17 rev A



Released 4-4-2014

ECO- 2.4 4/4/2014 page 18 rev A



Released 4-4-2014

ECO- 2.4 4/4/2014 page 19 rev A



Released 4-4-2014

ECO- 2.4 4/4/2014 page 20 rev A



Released 4-4-2014

ECO- 2.4 4/4/2014 page 21 rev A



Released 4-4-2014

ECO- 2.4 4/4/2014 page 22 rev A



Released 4-4-2014

ECO- 2.4 4/4/2014 page 23 rev A

Pages 9-10 were blank



Released 4-4-2014

ECO- 2.4 4/4/2014 page 24 rev A



Released 4-4-2014

ECO- 2.4 4/4/2014 page 25 rev A

ATTACHMENT 5

Non-Disclosure Agreement – Access to ITAR-Controlled Defense Articles by

Foreign National Employees in the United States

I, [name of foreign person], acknowledge and understand that any technical data related

to a defense article covered by the U.S. Munitions List to which I have access per authorization

by the U.S. Department, Directorate of Defense Trade Controls [state relevant export

license/authorization number] and disclosed to me in my employment by [name of U.S.

company] is subject to the export controls of the International Traffic in Arms Regulations (ITAR)

(Title 22, Code of Federal Regulations, Parts 120-130). I also acknowledge and understand

that should I inadvertently receive defense articles for which I have not been granted access

authorization by the U.S. Department of State, Directorate of Defense Trade Controls, I will

report such unauthorized receipt and acknowledge the transfer to be a violation of U.S.

Government regulations.

In furtherance of the above, I hereby certify that all defense articles, including related

technical data, to which I have access will not be used for any purpose other than that

authorized by the U.S. Department of State, Directorate of Defense Trade Controls and will not

be further exported, transferred, disclosed via any means (e.g., oral disclosure, visual access,

facsimile message, telephone) whether in its original form, modified, or incorporated in any

other form, to any other foreign person or any foreign country without the prior written approval

of the U.S. Department of State, Directorate of Defense Trade Controls.

________________________ _______________

Signature Date



Released 4-4-2014

ECO- 2.4 4/4/2014 page 26 rev A

ATTACHMENT 6

Non-Disclosure Agreement – Letter of Assurance for

Non-US “SAO-Affiliated Person”* To Permit Access to EAR-Controlled

“Technology and Software Under Restriction” (TSR) or for

Specific International Traffic in Arms Regulations Export License

I, [name of non-US person], acknowledge and understand that certain research or

technical data related to a controlled technology or software per the Commerce Control List of

the Export Administration Regulations (15 CFR Parts 730 – 774) to which I may have access

and or is disclosed to me in my affiliation with Smithsonian Astrophysical Observatory is subject

to export controls and is permitted by license exception TSR “Technology and Software

Under Restriction.”

The controlled research technology, data or software may not be disclosed to others

without permission by my advisor/supervisor. Such data or software will be marked “export

controlled – TSR.” These controls are related primarily to CCDs, adaptive optics,

deformable mirrors, high speed processors, rad hardened electronics, infrared

technology, instrumentation or encryption controlled by the U.S. Department Commerce,

Bureau of Industry and Security.

I also acknowledge and understand that should I inadvertently receive controlled data or

software for which I have not been granted access authorization by the U.S. Department

Commerce, Bureau of Industry and Security, I will report such unauthorized receipt and

acknowledge the transfer to be a violation of U.S. Government regulations. (Similar items and

technology as above that are “space qualified” may controlled as a ‘defense article” by the U.S.

Department of State, Directorate of Defense Trade Controls requires a specific export license

and to obtain such a license, I will be requested to provide information, such as a passport and

CV prior to any data release).

In furtherance of the above, I hereby certify that all controlled articles, including related

technical data, to which I have access will not be used for any purpose other than that

authorized by the provisions of the export license exception TSR (part 740.6 of the EAR) and

will not be further exported, transferred, disclosed via any means (e.g., oral disclosure, visual

access, facsimile message, telephone) whether in its original form, modified, or incorporated in

any other form, to any other non-U.S. person or any foreign country without the prior written

approval of the appropriate export license agency as indicated above.

________________________ _______________

Signature Date



Released 4-4-2014

ECO- 2.4 4/4/2014 page 27 rev A

* SAO-Affiliated Persons are any of the following: Contractors who perform work similar to Smithsonian employees, such as temporary help firms’ employees, volunteers, interns and fellows, visiting researchers, including scientists, scholars, students, and research associates.



Released 4-4-2014

ECO- 2.4 4/4/2014 page 28 rev A

SAMPLE ITAR LICENSE FOR NON-U.S. PERSON

SAMPLE ITAR FOREIGN NATIONAL LICENSE APPROVAL WITH PROVISOS

SAMPLE BIS LICENSE

ecp #2.4 export license procedures for tangible …...apr 04, 2014 · ecp #2.4 export license...

Documents